We believe the problem is easily addressed‭, ‬and the playing field leveled for all U.S‭. ‬ports if inspection fees are billed by volume rather than by unit‭.‬

Until two years ago‭, ‬USDA captured its costs of inspection and treatment in the‭ ‬“conveyance fees”‭ ‬charged to air‭, ‬land and ocean carriers‭. ‬However‭, ‬in 2015‭ ‬the agency created a new‭ ‬“treatment fee”‭ ‬to be charged directly to the shipments that are treated‭. ‬The fee has proven to be inequitable in its impact on trade because it is charged at the same amount for each treatment without regard to‭:‬

•‭ ‬Whether the treatment is the result of finding pests after inspection‭, ‬or is required automatically under standard procedures and without inspection

•‭ ‬The volume of perishable products to be treated‭.‬

The latter is the most significant inequity‭. ‬A single treatment in Florida ports typically involves a single trailer‭, ‬whereas a‭ ‬single‭ ‬“treatment”‭ ‬in northeast ports typically involves a warehouse load of multiple containers‭.

We believe treatment fee increases may be viewed negatively by countries that export fruit and vegetables to the United States, and could result in retaliatory customs duties and trade policies — all of which will be passed along to importers.

Until 2015‭, ‬when new APHIS fee regulations‭ (‬APHIS-2013-002‭) ‬went into effect‭, ‬USDA’s Agricultural Quarantine and Inspection Services‭ (‬AQI‭) ‬Treatment fees had remained the same for many years while the actual APHIS costs for monitoring the compliance of protocols and procedures for these treatments increased‭, ‬according the USDA‭. ‬Operating‭ ‬at a loss for these treatments‭, ‬the USDA implemented a rule change intended to bridge the gap by increasing the treatment fees‭ ‬incrementally from‭ $‬47‭ ‬to‭ $‬95‭ ‬in 2015‭, ‬to‭ $‬142‭ ‬on Dec‭. ‬28‭, ‬2017‭, ‬and to‭ $‬237‭ ‬in 2019‭. ‬Obviously‭, ‬a 202‭ ‬percent fee increase from‭ $‬47‭ ‬to‭ $‬142‭ ‬is exorbitant‭, ‬and an additional 67‭ ‬percent increase on top of that is cost prohibitive‭.‬

We believe the increased fee should be frozen until a better‭, ‬more equitable solution can be agreed upon between the USDA and the produce shipping industry‭.‬

In addition‭, ‬we believe treatment fee increases may be viewed negatively by countries that export fruit and vegetables to the United States‭, ‬and could result in retaliatory customs duties and trade policies‭ ‬‮—‬‭ ‬all of which will be passed along to importers‭.‬‭‬

This unbalanced discrepancy is especially alarming after ports in South Florida worked closely with the USDA to expand a cold treatment pilot program that allows new types of fruit to be imported from the Caribbean‭, ‬Central America and South America‭. ‬This‭ ‬was done in a spirit of cooperation that we believe needs to be rekindled to find a new solution to the current imbalance in the‭ ‬AQI fee structure‭.‬

We are concerned high fees will adversely impact port businesses and the jobs they support‭. ‬It is our hope that the fee increases included in the AQI rule will be frozen and reconsidered‭.‬

Steven M. Cernak, P.E., PPM, is the chief executive of Port Everglades, Fort Lauderdale, FL, and port director and chairman of the American Association of Port Authorities.